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NOT FOil DEStGN oa CONSTIIUCTION USE;
LOCA 110N AND DIMENSIONS ,.IIE FOil
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SCALE IN III£TERS
o
FIGURE 18
REMEDIAL ACTION 4
CONTAINMENT OF SITE CONTAMINANTS WI A MULTIMEDIA CAP AND GROUNDWATER BARRIER
JOG CREEK FARM SITE. HOWELL TWP.. NJ
100
,.......
100
"
Sf
rn~~
o A Halliburton Company
-------
-31-
the trench ,filling voids between soil particles and running
into the Upper Kirkwood Aquifer. This inundation of soil by
organic liquids is a separate mechanism of migration from the
convection of contaminants with the groundwater and accounts
for the extremely high levels of TVOs in the ground immediately
around the trench. Further away from the trench, soil contami-
nation is due to the transport of chemicals in the groundwater.
This migration depends on both the solubility of a given con-
taminant in water apd the affinity of the soil for the'
contaminant.
Some contaminants, notably ethyl benzene and 2-butanone, have
been found in the soil at the site but not in the brook indicating
high soil affinities or rapid volatilization in the brook.
Other contaminants, particularly non-volatile constituents such
as isophorone and several phthalates have been found commonly
in the soil but not in the groundwater or surface water. These
contaminants will be most effectively removed by excavation.
However, contaminants such as trichloroethene, tetrachloroethene,
1, 1, 1-trichloroethane, and 4-methyl-2-pentanone were not found
in many soil samples but were common in groundwater samples and
surface water samples from the bog and the brook. Benzene was
also not common in soil samples but was found in the groundwater
and in the bog. Excavation of residually contaminated soils
will not remove these contaminants from the aquifer, but removal
of the waste source will prevent future contamination of the
aquifer, and removal of bog and pond waters and sediments will
protect the public and the environment from high levels of these
chemicals at the surface. The dewatering operation required
for the more extensive excavation options will remove much of
the contaminated water from the aquifer.
To prevent continual, long-term contamination of the groundwater
and surface water, it is essential, as part of an excavation
alternative, that the waste source be removed. Excavating only
the waste trenches will not remove the soils that are highly
contaminated with the more fluid wastes. This excavation will
therefore fail to meet the CERCLA goal of adequately protecting.
pUblic health and the environment, since a massive source of
hazardous chemicals would continue to enter the groundwater and
migrate to the surface even after implementation. Four additional
excavation options, which involve excavating the waste trench
and additional contaminated soils, are discussed below.
The 10,OOO-ppm TVO and 100-ppm TVO concentration contours described
earlier define the horizontal limits for the four remaining ex- .
cavation options. The other distinction is related to the ease
-------
-32-
into a stratum above the water table, the vadose zone, and a
stratum below the water table, the saturated zone. Excavating
soils in the saturated zone requires dewatering the site. This
involves installing a temporary sheet pile cutoff wall and
pumping wells to lower the water table. The five excavation
options include: excavating the waste trench only, the -Source
Excavation-; excavating to the 10,000-ppm TVO contour in the
vadose zone only; excavating all soil within the 10,000-ppm TVO
.contour above and below the water table, this option has been
.termed the -Limited Excavation;- excavating to the 100-ppm TVO
contour in the vadose zone only; and excavating all soils
within the 100-ppm TVO contour, which has been termed the -Site
Excavation.-
The vadose zone excavation options were both eliminated from
further consideration in the technical screening stage. An
analysis of the soil- data shows that contaminants have tended
to migrate downward into the saturated zone. The cross-sections
(Figures 5 through 9) help illustrate how a deeper excavation,
into the saturated zone, is required to remove the bulk of the
residual contamination. Figure 19 presents approximate per-
centages of residual contamination removed versus the cost of
hauling and disposing of the material offsite. This cost/benefit
analysis, while utilizing off-site disposal costs for comparison,
is relevant to the excavation discussion in general, regardless
of the disposal option utilized. The percentages given in this
figure are based on the estimated volume of waste material
outside of the trench only. The material within the trench is
too heterogeneous for its mass to be calculated. The most
striking comparison can be made between the Limited Excavation
which removes 50% of the residual contamination for one-half
the cost of the 100-ppm vadose excavation, which removes only
20%. The vadose zone excavations are less effective than the
corresponding total excavations and are not significantly less
expensive. For this reason, vadose zone excavations were
eliminated from further consideration.
THE REMAINING EXCAVATION OPTIONS ARE LIMITED EXCAVATION AND
SITE EXCAVATION.
Limited Excavation will remove the most contaminated soils as
well as the waste deposits. TVO concentration data from the
three-dimensional sampling grid has allowed the determination of
approximate limits for a 10,000-ppm excavation. The actual
limits may need to be refined during design by additional sampling.
In any event, field measurement of TVO concentration will need
to be used during implementation to ensure that all soils with
concentrations above. 10,000 ppm are removed. Excavating additional
contaminated soil will further protect public health and the
environment by removing high concentrations of hazardous contam-
-------
~
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iii
en ~ 14
n
:ca 10
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ill 5 : ~
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20 30 40 eo
8V. OF RESIDUAL CONTAMINANT (TVO) REMOVED
NOTE: RESIDUAL CONTAMINANTS ARE THOSE CONAMINANTS
REMAINING IN THE SOil AFTER EXCAVATION AND
REMOVAL OF THE TRENCH AND TEST PIT N 0.'
RELATIVE EFFECTIVENESS SUMMARY FIGURE 19
BOG CREEK FARM SITE. HONELL TWF? NJ
~
16
4
2
KEY TO (4VERAGE HAULING 8 DISPOSAL COSTS
.
;
.
--II--
O. LANDFIWNG
I INCINERATION
.
.
.
.
!
~
.
NOTE: COSTS ~ LOWERING GROUNDWATER TABLE NOT INCUI)EI).
CAPITAL COS1S FOR LOWER1NG GROUNDWATER ARE PROJECTED TO
-------
-34-
additional excavation will also aid the restoration of the
shallow aquifer thereby accelerating the return of Squankum
Brook to b~ckground condition. Compliance with other environ-
mental statutes will depend on the effectiveness of the addi-
tional excavation with regard to reducing releases from the
site to background levels. It is possible that this option
will comply with all other environmental laws.
The Limited Excavation involves the removal of 14,000 cubic
yards of highly contaminated material. Much of this material
contains only residual contamination which may be removable
by some form of soil washing or soil air. stripping. Using a
soil washing technology and returning treated soils to the
site would eliminate the need to dispose of large quantities
of hazardous material. As such disposal is extremely expensive,
on-site soil washing offers a most advantageous alternative
for the handling of this waste. However, there is a lack of
information regarding the feasibility of using soil washing
at this site. EPA's Office of Research and Development (ORD)
has been approached in regard to conducting a study to determine
the applicability of this technology. ORD maintains a mobile
soil-washing unit in Edison, New Jersey that may be usable at
the site., An evaluation of soil washing should be conducted
concurrently with the design for the rest of this remedial
action.
Site Excavation at Bog Creek Farm will remove
soll contamination to background levels. The
with direct contact of wastes or contaminated
eliminated.
virtually all
risks associated
soils will be
Some contamination may remain in the Upper Kirkwood Aquifer,
although much of the affected water will be removed by the
dewatering operation. The residual contaminants will migrate
in small amounts to the North Branch of Squankum Brook until
any residual contamination has flushed from the aquifer. This
release may never be detectable above background levels in
Squankum Brook. In this event, this option would be in
compliance with all other compliance with all other environ-
mental laws. If some release of contaminants does continue,
this option may still attain standards of other environmental
laws through the setting of Alternate Concentration Limits.
This topic is more completely addressed later in this document.
The effectiveness of the Site Excavation alternative exceeds
that of all other excavation options. However, the cost of
implementing this alternative is much greater than the cost
of implementing Limited Excavation. The higher cost is due
to the increased volume of material to be handled and disposed.
The volume of material to be managed may be significantly
reduced by segregating clean and contaminated soils, soil
washing the less contaminated soils, and returning the treated
soils to the site. An evaluation of the feasibility and cost
of implementing soil washing will be conducted concurrently
-------
-35-
Figure 20 provides a site layout for Alternative 5 and approximate
limits for all of the excavation options.
Alternative 5 - Excavation With Off-Site Disposal
This alternative considers both disposal at an off-site landfill
and incineration at an approved facility. It should be speci-
fically noted that the intent of this Record of Decision is to
consider both off-site and on-site incineration disposal options,
depending on applicable costs at the time of implementation.
On-site disposal is considered in the final two alternatives.
Off-site land disposal has several problems associated with it.
It may cause project delays if RCRA landfill space is not
immediately available, it is very expensive, and it is an
unreliable means of disposal for material with high concentrations
of very mobile compounds such as the Bog Creek Farm waste. In
contrast, incineration offers destruction of the hazardous
chemicals in the waste deposits and soils. The high concentrations
of volatile chemicals make this waste more amenable to incineration
since less heat is required to vaporize the chemic1s for burning.
Despite its higher cost, incineration is a more environmentally
sound means of disposal for the Bog Creek Farm waste. As
mentioned previously, these costs may be reduced by implementing
soil segregation and soil washing.
Compliance with other environmental laws is dependent on the
level of excavation chosen. The facility chosen to receive the
waste from the site must be in compliance with all environmental
laws. As discussed previously, Limited and Site Excavations
implemented as part of this alternative should attain or exceed
all applicable and relevant Federal standards.
A summary of the costs associated with both of these disposal
options for each level of excavation is presented graphically
in Figure 19. Capital costs and present worths for each
excavation option are presented in Table 3.
Alternative 6 - Excavation With On-Site Disposal in a Landfill
On-site disposal of excavated waste and contaminated soil was
also developed as an alternative. This alternative includes
all the elements of excavation with off-site disposal as
discussed (bog and pond removal and subsequent cover, fencing
the site, and covering the site) except for disposal at an
off-site facility. This alternative will create a RCRA-
approved landfill at Bog Creek Farm. The draft feasibility
study performed by NUS only considered utilizing an on-site
landfill for the Source and Limited Excavation options. The
area needed for landfilling of the material generated by the
Site Excavation option exceeded the property boundary and for
this reason, the option was not considered. This artificial
-------
"
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.,/
.-
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1/ ..
,
. .,
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. Nor FOIl DESIGN 011 CONSJIIUC110N USE;.
lOCA 110N AND DIMENSIONS ARE fOR
fEASlIIUn S ruDY PUllroSES ONl Y
.'
so
I:
o
REMEDIAL ACTION ALTERNATIVE 5
EXCAVATION OF WASTE DEPOSITS WITH OFFSITE DISPOSAL IN AN APPROVED FACILITY
BOG CREEK FARM SITE. HOWELL TWP. NJ
100
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SCAt.L . IlETtRS
o
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SCALE. FEU
lOG
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FIGURE 20
t:tj~~
-------
-37-
on-site landfilling of the material removed in the Site Ex-
cavation option have been developed by NUS and included in
Table 3 of this document. This information will be included
in an addendum to the final feasibility study report. The site
layout is shown in Figure 21.
Enviro~ental considerations peculiar to this option relate to
the presence of a landfill at Bog Creek Farm. Constructing a
landfill at the site will greatly increase operation and main-
tenance costs and. responsibilities. In addition to environmental
monitoring, the landfill will require perpetual, periodic
maintenance, and replacement or overhauling at the end of its
useful life. Failure to provide essential maintenance would
endanger public health and the environment; and the site would
revert to its present condition. Negative aspects of off-site
landfilling which do not apply to this alternative are the use
of limited space in a RCRA landfill and the associated costs
and delays encountered in implementing such an alternative.
For Limited and Site Excavation, on-site landfilling is con-
siderably less expensive than off-site disposal. Capital costs
and present-worth analyses are provided for all three excavation
options in Table 3.
This alternative may comply with other environmental laws.
However, the performance of the landfill is critical to meeting
this goal. The potential for leakage of the highly mobile
contaminants present at the site makes this alternative less
reliable than Alternative 5.
Alternative 7 - Excavation With On-Sit~ Treatment and Disposal
The final remedial alternative considered for Bog Creek Farm in
the draft feasibility study prepared by NUS includes performing
the Site Excavation option, reducing the volume and hazardous
quality of the excavated material by incinerating it in a
temporary on-site incinerator, and disposing of the end product
in an on-site RCRA landfill. Several points need to be made
relating to this option. First, there is a great likelihood
that the by-product of incineration will not be hazardous and
will not require the environmental controls mandated by RCRA.
This will reduce the costs to implement this alternative.
Second, the NUS study only estimated the costs associated with
the incineration of the material generated by the full Site
Excavation option, not the lesser volume associated with the
Source and Limited Excavation options. Although the feasibility
study did not consider on-site incineration for the less extensive
excavations, it is not the intent of this Record of Decision to
limit the disposal of this material to off-site incineration.
On-site incineration will be fully considered as a disposal
option regardless of the volume of material to be handled.
Compliance with other environmental laws is the same for this
-------
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~.;~<~~~.-:- ,,,/ ,"", ,,' .~.!J{-r:-"r.' ~ ;\\.~.
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REMEDIAL ACTION ALTERNATIVE 6 .
EXCAVATION OF WASTE DEPOSITS WITH ONSITE DISPOSAL IN A DOUBLE-LINED. MULTIMEDIA.CAPPED LANDFILL
BOG CREEK fARM SITE. HOWELL TWP.. NJ
"....
NOT FO. O£SlGN ~ CONSTIIUCTlON USE;
lOCA nON AND DIMENSIONS AilE FO.
FEASlIIUTY STUDY I'UIII'OSfS ONl Y
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SCALE 11l1li[ T£IIS
FIGURE 21
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-------
-39-
Figure 22 presents the site layout for the alternative as de-
veloped in the feasibility study, that is, the layout includes
the placement of an on-site incinerator as well as the siting of
a RCRA landfill as needed for the Site Excavation.
Discussion
The alternatives developed for Bog Creek Farm fulfill the National
Contingency Plan re.quirement in that at least one alternative
from each of the following groups is considered: the no-action
alternative; alternatives that do not attain applicable or
relevant environmental standards but provide significant protection
to public health, welfare, and the environment; alternatives
that exceed applicable or relevant environmental standards;
alternatives that attain applicable or relevant environmental
standards; and alternatives that use treatment or disposal at
an off-site facility. In accord with the off-site policy,
alternatives that utilize treatment in addition to, or in place
of land disposal have been carried through the screening process.
Alternatives that utilize only on-site treatment and disposal
have also been developed.
Several alternatives. were dropped from further consideration in
initial screening. The reasons for eliminating these alternatives
were discussed previously and are summarized as follows:
~ the two alternatives that employed caps and sheet pile
cutoff walls to contain the wastes were eliminated due to
a lack of effectiveness and the potential for detrimental
environmental effects,
- the two vadose-zone excavation options were eliminated
because of their low effectiveness compared to other
excavation options with similiar costs,
- the No Action Alternative and the Source Excavation option
fail to meet any of the remedial objectives ahd would
allow at least part of the source of concentrated hazardous.
materials to remain at the site threatening public health,
welfare, and the environment.
One of the remaining alternatives is Site Closure with Multi-
media Cap and Groundwater Pumping. The containment associated
with Site Closure is relatively unreliable and ineffective.
This alternative would reduce leachate production by eliminating
infiltration, but depends on groundwater pumping to contain the
contaminated groundwater plume. Since the source deposits of
waste would remain at the site, groundwater pumping would be
required indefinitely. During high water-table periods, the
waste itself may be located within the saturated zone, causing
-------
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f;~" ':-....... """, .-,~:~. C' . ','~'~: - '" '
,.y,~'~"~ 6~,"""~><"1('-- .\.:.- "...."."g~,\.~ "
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.- "..' t.."""""l""'''' ," ,ExaNJoTlONAAEA ." ';'; "", ',,:' '.c~ ~.
----, ----------' . ----, . ('~ ., . . t .'..' ~.. "to-..,.-:::'
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. 1..1T11IO WILLS UTILlZlDIS'.,l \,,~ -,,',- ,. ", /-'--",,9 j, ~~~~~~~~No?:~S~~~~UI.'C::~~~SE;
--- fEASI8IUTY STUOY 'URPOSES ONl Y
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REMEDIAL ACT10N 1 SCALI .. .'I[T[IIS
FULL SCALE EXCAVATION WITH ONSITE INCINERATION AND DOUBLE' LINED.MLt.TIMEDIA CAP LANDFILL 100 0
, 806 CREEK FARM SITE. HOWELL TWP. NJ r:"""II ;;L[ IN ft:n
3'
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FIGURE 22
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efj~
-------
-41-
release of contaminants to Squankum Brook would continue. If
the groundwater pumping system proves ineffective or if it is
ever discontinued, continuous release of contaminants to Squankum
Brook will- resume. This would probably constitute a violation of
applicable RCRA regulations.
The final two alternatives to be considered are the Limited
and Site Excavations utilizing various means of disposal.
Both alternatives remove the waste deposits and offer protection
from future exposure of this hazardous material. They differ
in the amount of contaminated soil to be removed.
If the Limited Excavation option is implemented, soils with
total volatile organic concentrations approaching 10,000 ppm
will remain on-site. Direct contact with this level of contam-
ination is possible and some of the contaminants left in the
soil will leach into the groundwater and migrate to the North
Branch of Squankum Brook. Based on preliminary modeling, the.
migration of contaminants will be less severe than it is currently.
A decision to pursue the Limited Excavation option will require
additional site-specific risk/transport modeling to ensure that
the continued release does not pose any threat to public health
or the environment.
Site Excavation will remove virtually all contaminated soil
from the site. Furthermore, contaminants in the groundwater
will be mostly removed by the dewatering operation. It is
possible that no future release of contaminants will occur if
this alternative is implemented. Site Excavation is considerably
more expensive than Limited Excavation, but the environmental
benefits are greater.
The cost of excavation and the problems associated with disposal
of a tremendous quantity of waste may be significantly reduced
by utilizing on-site soil segregation and soil washing. For
example, in the case of Site Excavation, an estimated 35,000
cubic yards of excavated soil may be clean. If this soil can
be separated and returned to the site, and if soils containing
less than 10,000 ppm TVO can be soil washed and returned to the'
site, only 10,000 cubic yards of material may need to be hauled.
off-site to a landfill or incinerator. This would substantially
reduce the cost for disposal. The cost of the alternative will
be increased by the additional costs of soil segregation and
soil washing, but the hauling and disposal savings may be more
significant, resulting in a net cost reduction. Similarly some
savings could also be realized if this approach were applied to
the Limited Excavation option. Recovering chemicals from the waste
trench for reuse has been dismissed as an infeasible approach
to achieving a net cost reduction despite the high levels of
chemical contaminants present.
The feasibility and cost of soil segregation will need to be
determined during detailed design of the alternative, and the
feasibility and cost of soil washing will need to be determined
by a study of this technology. EPA's Office of Research and
Development has already been approached with regard to conducting
-------
-42-
There are basically four disposal options which can be applied to
the material excavated from the Bog Creek Farm site:
- disposal in
- disposal in
destruction
destruction
an on-site RCRA landfill,
an off-site RCRA landfill,
in an on-site incinerator, and
in an off-site incinerator.
The major negative aspect of the on-site landfill involves the
the permanent maintenance requirement which potentially lowers
the reliability of this alternative, and the eventual need to
overhaul or replace the landfill which increases its long-term
cost.
The off-site landfill disposal option is subject to overall
capacity constraints, high cost, and potential delay due to
unavailable disposal capacity at the time of construction. "In
addition, the material at Bog Creek Farm is highly concentrated
and mobile and would best be handled by total destruction rather
than by land disposal, with all its associated monitoring and
maintenance costs.
Incineration offers ~he best alternative in terms of reducing any
long-term environmental threat, although the cost is greater.
The Bog Creek Farm material, being highly concentrated, is
particularly amenable to incineration. Both on-site and off-site
incineration are believed to be technically and environmentally
sound alternatives and need not be differentiated at this time.
Selection of on-site versus off-site incineration should be a
function of the technology available and cost at the time of
project implementation.
COMMUNITY RELATIONS
On 14 August 1985, EPA made the draft RIfFS available for
public comment by placing three copies of these documents in
public repositories at the Howell Township Municipal Building
and the Bowell Township Public Library. The public was notifiea
of the availability of the documents by a letter to the township
administration and a news release sent to all those on the Bog
Creek Farm mailing list. The public comment period began on
this date and extended through September 13.
A public meeting was held on 5 September 1985 to present the
findings of the RIfFS, propose a remedial action, and respond
to public comment. This meeting was attended by four repre-
sentatives of EPA, three employees of NUS Corporation, the
NJDEP site manager, a representative of the Monmouth County
Health Department, the Bowell Township administration and
several residents of Bowell. Public concern centered on the
availability of Superfund money in light of the impending need
for CERCLA to be reauthorized and rapid implementation of the
-------
this site have been very limited. A Responsiveness Summary,
based on comments from the public meeting, is attached to this
document.
~ONSISTENCY WI~H OTHER ENVIRONMENTAL LAWS
Wetland~ Assessment
The bog at Bog Creek Farm is a very small wetland occupying
less than two-tenths of an acre. In accordance with Executive
Order 11990, the present condition of this wetland, the likelihood
of successful remediation, and the environmental and public
health threats presented by its continued existence were considered.
Also, the plans for remediating this site were made available
to the public on 14 August 1985 and a public meeting was held
on 5 September 1985 to discuss remediation of Bog Creek Farm.
The public comment period ran through 13 September 1985. At
this time, the surface of the bog is highly contaminated with
organic and metalic chemicals. In the interest of protecting
public health and the environment, contaminated waters and
sediments should be removed from this bog.
The contamination in .the bog is the result of groundwater
discharge from the Upper Kirkwood Aquifer. Therefore, draining
and dredging the bog would only temporarily solve the problem.
It is essential to regrade and cover this area to prevent it
from re-forming as a contaminated wetland. Other wetlands,
some much larger than this one, are present nearby along
Squankum Brook and the Manasquan River, therefore it appears
that this bog does not provide a unique environment or habitat.
Compliance With RCRA
The remedial alternatives developed for Bog Creek Farm were
examined to determine to what extent residual contamination
would continue to migrate from the site. For the purpose of
evaluating compliance of these alternatives with RCRA, the
property line was used as the facility boundary. Alternatives
were assessed with regard to the potential for contamination to
migrate beyond this boundary. The mechanism for such migration
is convection with the groundwater. This migration could also
carry site contaminants into the North Branch of Squankum Brook
which could constitute a violation of Clean Water Act regulations
as well. Since RCRA requires the more stringent requirement
that releases not exceed background levels, this criterion was
used as a goal for all remedial alternatives. .
Site Excavation may immediately reduce releases from the site
to below background levels, thereby exceeding relevant environ-
mental standards. Limited Excavation may allow some release of
contaminants from the site until the aquifer has flushed.
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-44-
the duration of these releases could be shortened. The limited
yield of the Upper Kirkwood Aquifer precludes high pumping
rates, severely limiting the effectiveness of this remediation
scheme. The contaminants released after Site Excavation will
be less concentrated than current levels, and within five to
ten years, Bog Creek Farm will not contribute to contamination
of the brook. Other than Limited and Site Excavations, all
~lternatives considered allow permanent migration of some level
of contamination from the site.
The contamination of Squankum Brook may be reduced below back-
ground levels or may require setting an Alternate Concentration
Limit (ACL) in accordance with RCRA. A determination as to
the allowable level of residual soil contamination will be
made using site-specific exposure/risk modeling to demonstrate
that any residual poses no threat to health or the environment.
Preliminary groundwater modeling has indicated that Limited
Excavation may reduce contaminant loading to the North Branch
of Squankum Brook to sufficiently low levels to justify setting
an ACL. '
RECOMMENDED ALTERNATIVE
The National Oil and Hazardous Substances Pollution Contingency
Plan, in 40 CFR Part 300.68(i), specifies that the lead agency
will select 8... a cost-effective remedial alternative which
effectively mitigates and minimizes threats to and provides
adequate protection of public health, welfare and the environment.
This will require selection of a remedy which attains or exceeds
applicable or relevant Federal public health or environmental
standards..." In addition, 40 CFR Part 300.68(d) states that
"Response action may be conducted in operable units. ...In some
instances, implementation of operable units can and should
begin before selection of an appropriate final remedial action
if such measures are cost-effective and consistent with a
permanent remedy." Evaluation of the suggested remedial alter-
natives leads to the conclusion the action described below is a
cost-effective operable unit consistent with a permanent remedy
for the Bog Creek Farm site.
The various aspects of the recommended alternative are described
below along with the rationale for selection:
Three levels of remediation were evaluated for the bog and
the pond, both of which are highly contaminated at the surface,
At a minimum, both the bog and the pond must be regraded to
prevent groundwater aischarge from re-fo~ing contaminated
wetlands in these areas. However, this action would afford
only minimal protection from future contact with the highly
contaminated materials left behind. A slightly more expensive
action would be to regrade and then cover the areas with
clean fill or a compacted cap. Although this would offer
additional protection from direct contact or eventual exposure
-------
-45-
additional cost, the contaminated bog and pond sediments can be
removed. The cost-effective remedial action for the pond and
the bog involves dredging to a depth of approximately three
feet, regrading, and covering with additional fill as necessary
to prevent reponding.
Several levels of excavation were considered for the waste-
disposal area. Site Excavation offers removal of nearly all
contaminated material and immediate reduction of contamination
of Squankum Brook. . Limited Excavation leaves highly contaminated
soils below the surface at the site, but preliminary modeling
indicates that contamination migrating from the site may be
reduced from current levels.
Limited Excavation is considerably less expensive than Site
Excavation and is the recommended alternative. However, it
must be considered an interim remedy pending the results of
more extensive groundwater mOdeling. Currently, compliance
with RCRA requires removal or treatment of contaminated
material down to background levels, a maximum contaminant
level, or an ACL. Until the site-specific modeling is fully
performed, no decision will be made as to an allowability of
an ACL. This approach is described in the 8 July 1985 memoran-
dum from John J. Stanton, Director, CERCLA Enforcement Division
to David Buente, Chief, Environmental Enforcement Section, DOJ.
Environmental monitoring will be required after implementing
Limited Excavation to confirm the predictions of groundwater
modeling and assure the effectiveness of the remedy. If it is
found that Limited Excavation fails to provide adequate
protection of public health and the environment, additional
excavation may be required.
The remedial design will determine whether it is feasible to
segregate excavated material from the waste disposal area, the
bog, and the pond. Concurrent with the remedial design, a
study will be conducted in conjunction with the Office of
Research and Development to determine the feasibility of using
some form of soil washing at the site. If it is found that
such a technology can be cost-effectively applied, treatable
soils may be decontaminated and returned to the excavation pits.
80il segregation and soil washing are two innovative technologies
that, if implemented, will enhance the cost-effectiveness of
this alternative by reducing its overall cost or by reducing
the amount of material which will need to be handled.
Contaminated water will be removed from the pond and the bog,
and groundwater will. be pumped to facilitate the deeper
excavation at the site. This water will be treated on-site
in a temporary unit utilizing air stripping and activated-
carbon treatment. This option was compared to off-site treat-
ment in the feasibility study and found to offer equivalent
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-46-
After consideration of the nature of the contaminated material
at 80g Creek Farm, it is recommended that this material be
totally destroyed by incineration rather than disposed of in a
RCRA landfill. Consistent with EPA's CERCLA off-site policy,
it is believed that the long-term environmental and public
health benefit outweighs the additional cost. No differentiation
is being made at this time relative to on-site versus off-site
incineration. 80th methods are technically feasible and
environmentally sound. Final selection will be based upon the
availability of technology and capacity and the cost at the
time of implementa~ion. -
After the contaminated soil has been excavated and any clean
material returned to the excavation area, the site will be
backfilled and regraded to prevent ponding, and revegetated.
During implementation, monitoring will be conducted to ensure
compliance with this Record of Decision. At the completion
of the remedial work, a follow-up. monitoring program will be
initiated to ensure the effectiveness of the action. This
program will involve monitoring groundwater, surface water,
and sediments periodically. .
Prior to initiating remedial work at the site, a security
fence, an access road, a contamination reduction area, and
any other support facilities needed will be constructed.
""
A detailed cost summary is provided in Table 4. Note that
these costs are based on off-site landfilling. As illustrated
in Figure 19, the cost for off-site incineration is approximately
2,800,000 dollars greater.
OPERATION AND MAINTENANCE (O&M)
Operation and maintenance of the site will include long-term
monitoring and maintenance of the vegetation and soil cover.
The costs for these two activities are anticipated to be
$38,800 per year for sampling and anlysis and $15,600 per
year for site maintenance. Environmental monitoring will be
required until the effectiveness of the remedy is assured.
Operation and Maintenance will be funded as specified in CERCLA
and the NCP. .
SCHEDULE
!!£ject Milestone
- Approve Remedial Action
- Complete Enforcement Negotiations
Date
-
September )985
14 October 1985
- Award State Contract
Pending CERCIA
Reauthorization or
-------
-47-
- Initiate Design
Pending CERCLA
Reauthorization or
State Funding
Pending CERLA
Reauthorization or
State Funding
~
- Complete Design
FUTURE ACTIONS
Additional studies required to implement the selected alternative
have been discussed above. In summary, they include:
- An evaluation of the feasibility of using soil segregation
to reduce the volume of excavated material to be incinerated.
This analysis should be conducted as part of the detailed
design of this alternative, .
- An evaluation of the feasibility of using soil washing
to reduce the volume of excavated material to be incinerated.
This study will be conducted in conjunction with ORD, and
- A more detailed site-specific exposure/risk modeling to
better define the threat that residual contaminants pose
to public health or the environment. This modeling
effort will aid in setting an ACL or deciding to remove
all material down to bakcground levels.
An environmental monitoring program, which calls for sampling
groundwaters, surface waters, and sediments impacted by the
site will be initiated as part of the implementation of the
selected alternative. If sampling results indicate that the
implemented remedy is failing to meet the stated goal of CERCLA,
of protecting public health and the environment, a second
operable unit will be selected and implemented. The second
unit may include performing addtional excavation if it is
determined that such an action is required. To assure consistency
with this potential additional remedial measure, the design of
the alternative selected in this Record of Decision should
consider extending the excavation to the soils within the 100-
ppm contour and upgradient from the recommended excavation
limit. This precaution is considered prudent so that material
used as backfill in the first operable unit can be segregated
as clean material should a second operable unit involving
-------
-48-
Table 4
Detailed Costs Of Recommended Alternative
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-------
ATTACHMENT 1
Responsiveness Summary
Public Meeting
-------
Topic:
Issue:
Discussion:
.ssue:
Discussion:
Issue:
Discussion:
REMEDIAL INVESTIGATION/FEASIBILITY STUDY
RESPONSIVENESS SUMMARY FOR THE
BOG CREEK FARM SITE
. HOWELL TOWNSHIP. Jl)NtIJUTH COUNTY. NEW JERSEY
BASED ON CtllDTS FROM
PUBLIC MEETING OF
SEPTEMBER 5. 1985
Public Health Concerns
What is going to be done during the 6 to 8 month period, when the
bid document is being prepared, to prevent human contact with the
5011 and to reduce the danger to the environment? Is the site
fenced? I know that area children, Boy Scouts, and campers go.
back there and play in those streams. Are there going to be
warning signs put up, and if so, what will they say?
.
There are warning signs at the site. They are large white signs,
posted on all 4 corners of the site. They warn that the area is
a hazardous waste site and that it is a project of the
Environmental Protection Agency and the New Jersey Department of
Environmental Protection. The signs also include EPAls phone
number in case anyone should have any questions. Incidentally,
these signs were put up as a result of publ~c ~nput.
.
My concern relates to the middle of the site between the signs--
that is, where there are no signs posted. Children may not see
the signs on the corners of the site. My opinion is that if it
is going to take 6 to 8 months before construction, then that
area of the site should be fenced to keep people out of that area
and away from the stream. I don It think a sign is good enough.
Thank you. We will take your comment into consideration.
Could you tell me what chemical was detected in the lar~est
concentration at this site? .
Toluene. In the actual waste, one sample showed toluene at about
18 percent, but that was not an environmental sample, such as
sol1, air, groundwater, or surface water. Th,t was an actual
sample of a resin that we dug out of a test pit.
-------
Issue:
Discussion:
Topic:
Issue:
Can my child walk to that place?
No. That sample would have been between 10 and 20 feet below the
surface; we obtained that sample from a small-diameter boring
that we made into the ground, which is now sealed. We found no
contamination at that high of a level on the surface. The
highest levels of surface contamination that we found were in the
bog, where the total of all volatiles reached as high as 200
parts per million.
Technical/Re8edial Action Considerations
What was the total area included in this study?
Discussion: The area under study was roughly 4 to 5 acres. We found out that
the contamination was limited to about 2 acres.
Issue:
Discussion:
Issue:
Discussion:
Conment:
Conwnent:
In that trench that you identified, is the contamination
.[contained] in barrels, or was it dumped loosely? .
The 150 foot trench was used for uncontained chemical wastes.
The other disposal area did contain about 6 drums, but they were
crushed and empty. There may have been some residual waste in
the drums. Most of the contaminated materia 1 s were from
uncontained chemical wastes. .
If you have canoed or hiked down the Manasquan River, you would
notice that there is a difference in the water color and that
there is a putrid chemical odor where the Squankum Brook enters
the Manasquan River. Did you investigate that?
We conducted our testing all the way down to the confluences of
the Squankum and Manasqaun. We took two rounds of sampl es and
evaluated the site-related chemical compounds--roughly 150
different chemical compounds that we normally test for on these
types of sites--and we did not see any appreciable change in
water quality in the Manas~uan as a function of the Squankum
,
input.
Squankum Brook is the major southern drainage of the Manasqu.an
River, and there is definitely a different color and cl&rity of
the wlter, 15 well 15 a lot less.l1fe--especially IS the seasons
. change and there is mOre rainfall.
I ride my horse quite frequently, and one day I took him down to
that area. When we came to the brook, my horse started to snort
and stomp Ind would not cross that stream. Obviously, he smelled
something that was foul to him, and this is the first time a
horse has ever acted this way with me. I ended up having him
jump the brook.
-------
Corrment:
Issue:
Discussion:
Issue:
Discussion:
We say these things to pOint out that we feel that there is
contamination i~ that area. Also, with regard to air pollution,
there is a rotten, noxious odor. During hot, humid weather, you
h~ve to leave your windows down. Sometimes, you even get sick.
We feel that this pond really helped us to identify the problem.
I would not be opposed to keeping a pond as a way of knowing when
and where the contamination is occurring. It is a key indicator.
By removing the pond, we are going to be removing the chemicals
as well. The removal w11l clean up the site. A1so, all of the
alternatives include long-term monitoring. We have monitoring
wells that directly bring water out of the aquifer, which is
where the pond water is coming from. We would be sampling the
water from those monitoring wells periodically and .as necessary.
We would a1so be sampling ~he surface water. At the site, we
have noticed the orange color, which our stream hydrologists
classified as iron spots and which are not that uncommon.
We a1so completed another round of surface water sampling last
week--an even more extensive round than we did before. We
sampled the surface water in the north branch of Squankum Brook
at four points between the site and confl uence with the south
branch. The reason we did even more points in that area was
because we noticed an increase in the contamination between where
the brook goes past the bog and where it has its confluence with
the south branch. We fee1 that the reason for the occurrence is
because the groundwater is flowing into the brook in that area
and contributing more contamination, even though contamination
along that brook is volatizing and thus leaving the brook.
A phrase I hear mentioned frequently at these public meetings is
"long-term monitoring." How long is it, who pays for it, and who
is in charge of it?
It continues for 20 to 30 years, the State pays for it, and the
State is completely in charge of it. Under existing legislation,
the State is responsible for any operation and maintenance costs
after the first year that the system is built. .Under new
legislation that is being prop,osed, the Federal government coul~
be responsible for these operation and maintenance costs for a
longer period of time, maybe up to five years after the system is
built. .
-------
Issue:
Discussion:
Issue:
Discussion:
Issue:
Discussion:
I don't see an option listed on the handout for onsite treatment
with offsite disposal.
If. you look at Alternative No.5, there is an optional soil
washing. that is a remedial action that we are going to explore.
Removing the waste trench itself would, as we indicated earlier,
remove the vast majority of contamination. It would considerably
reduct the public health threat and the environmental impact from
the site as it exists now. Therefore, it is a very attractive
option because it is not as large an excavation as the other ones
mentioned.
If we were to implement that alternative, the soil washing
mentioned here as an option is something that would require
further study to determine its effectiveness. We could try to
flush those contaminanted soils that surround the waste trench by
injecting and pumping water from wells; essentially recirculating
it through the.site, treating it as we draw it from the wells.
Or we could excavate the waste trench itself, which is very
highly contaminated and which may not be suitable for treatment
in this way, and take it to an offsite disposal facility--either
an incinerator or an offsite landfill.
With the remaining contaminants on site, we could actually
excavate them and try using a treatment unit above ground to
either wash or airstrip those soils. If we could get them
sufficiently clean, we would then be able to return them to the
site at a much lower cost than if we took the contaminated
materials off site. That is an option we are considering as part
of Alternatives No.5 and 6, listed in the handout.
Would incineration be more efficient than the other proposed
alternatives?
We explored incineration on site as opposed to landfilling the
contami nated so11 s. The only reason we di d not go wi th
incineration is because 1tlcosts almost twice as much as the
other alternatives. However, it is still a consideration.
Have you thought about flushing the toxics out of the dirt?
Yes. The trench contains about 5,000 cubic yards of very
concentrated material--in our minds, too concentrated to try to
treat. We'd rather dig that material up and move. it out. There
are approximately 25,000 additional cubic yards of so1' which had
become somewhat contaminated as a result of this material that
was put into the trench and allowed to leak out. It is that
large volume of soil that we think we may be able to wash or
somehow treat.
.
-------
Issue:
Discussion:
Issue:
Discussion:
Issue:
Discussion:
Issue:
The intent is two-fold. We want to get the grossly contaminated
material out of there and we then want to see if we can treat the
larger volume of "material so that we do not have to pick it up
and haul it away.
What is the depth of the contamination?
The'depth of the contamination could extend to 20 feet, but the
trench itself is only about 10 feet deep, with a little material
"that seeps down further. The main contamination is within 10
feet.
Do you have any idea how many cubic yards you have to remove?
The tren~h contains about 5,000 cubic yards. In the bog, we
would proba~ly remove 10,000 to 15.000 cubic yards of material.
Where are you going to get the dirt to replace the dirt that you
excavate?
We can get dirt and fill; that is not a problem.
Once this place is excavated, will you revegetate the area?
Discussion: We will revegetate the area.
Issue:
Discuss ion:
Issue:
Discussion:
Issue:
Discussion:
If you are going to take this material to another place, what
w11l prevent that contaminated material from polluting the air
and groundwater at the new place?
We have a regulatory program under the Resource Conservation
Recovery Act, and under that program. hazardous waste landfills
have to be built and operated under certain procedures that
protect against material leaking out of the landfill. The
landfills are constructed with double-liners and with leachate
collection systems to protect the environment.
The problem with this site is that it didn't have a lined bottom.
The materials were just dumped loosely in the trenches.
,
You discounted pesticides from your study, and that really
bothers me.
We've taken a good look at the wastes on this site. What we're
looking at is the impact of this site on the environment. We've
identified mostly volatile organics. We do not feel there is a
pesticide problem at this site.
Did you conduct any studies on the effects of the chemicals in
the plants and animals in the food chain? Are plants and insects
contaminated?
We did not have the time or the money to conduct a b.iota study.
Our main concern is to remove the chemicals and contaminated
soi 15.
-------
Topic:
Issue:
Discussion:
Issue:
Discussion:
Issue:
Discussion: .
Cost/Funding Issue~
If this $7 million option that you are recommending turned out to
be satisfactory, what is the estimated time for bidding that work
out? (State Senator Gagliano speaking)
The next step in this process, once Christopher Daggett makes a
decision, is to prepare the design plans. My best estimate is
that it would take 6 to 8 months to advertise and contract this
work. The work would actually start sometime late next spring or
early sunmer.
Considering the present situation with respect to Superfund, can
this cleanup be funded for $7 million; that is. assuming
Christopher Daggett makes a decision and that you are able to
prepare the proper Requests for Bids and secure a contractor to
perform the work? (State Senator Gagliano speaking)
We have been.proceeding in the last month or so as if Congress
would reauthorize the Superfund at somewhere between the $5 and
10 billion level. That hasnlt occurred yet; Congress is not yet
back in session. Under the timetable welre looking at, it won't
be until mid-October before we could get a bill.
Are you saying that the present funding would not be sufficient
for a cleanup? (State Senator Gagliano speaking)
Present funding is between $300 and 500 million; that is, there
is tha t amount - of money 1 n the ban k. Lee Thoma s. EPA
Administrator. would have to decide how that $300 to 500 million.
would be spent. The belief is that even if Congress doesnlt
qui ckl y pass the new bill. there woul d be some type of
continuing resolution that would ~t least continue to collect tax
at a rate of somewhere between $300 and 400 million a year. So
one source of funding is Federal funds and that would be subject
to some priority setting by the administrator.
The second avenue 15 througf\, the State of New Jersey. which has
up to $250 mil110n in available money for such activity. The
State has already agreed to fund the preparation of the design
plans and bid document. which will take about 6 to 8 montns.
That would roughly cost about a half a lIi11ion dollars. That
gives us 6 to 8 months to at least get Superfund reauthorized.
and if that doesn't happen in 6 to 8 months. there is going to be
a lot of significant slowdowns in the area. We totally expect
that the $7 lIil110n will be there when we need to spend it. If
it were not for the State of New Jersey and their funding
sources. which are unique in the country. when we would sign the
Record of D~cis1on, work would essentially stop at this site.
What New Jersey allows us to do is to continue with that work. .
-------
Issue:
Discussion:
Issue:
Discussion:
Issue:
Topic:
Issue:
Discussion:
Issue:
If in fact we are not going to have reauthorization in 12 days,
then shoul d that decisi on be made by Chri s Daggett as to what
option will be chosen or should it be made by the State, at
least on a temporary basis, since they are going to be paying the
costs. I don1t want the State to be precluded. (Assemblyman
John O. Bennett speaking) .
Any decision that Chris Daggett makes for that Record of Decision
must concur with the State of New Jersey. We've already briefed
the State on this particular project and they are in general
agreement with our recommendation.
. Will there be a continuation of you as the lead agency if Federal
funding discontinues and the State pays for the cleanup?
We expect that if funding were to stop, it would be short term.
We don't feel that the State could support a long-term project.
As long as decisions are going to be made with maximum State
participation and public input will be accepted, then it's okay.
I just want to see it cleaned up. Welre giving you the money,
and I'd like to see us get'something in return.
Ad8infstratfv8 Issues
1 just want to say for the record that as a representative of the
legislature of this district, we have several sites. We are
totally frustrated. We've been to' hearings like this. We would
li ke to see one site tota 11 y cleaned up and then i nvi te people
there so that we. could say, 'This is what we've done with our
state money and with Superfund money, and with local cooperation,
we have taken a site and cleaned it rather than just studying
it.M I think the option for $7 million, though it's a lot of
money, is worth it. Could we somehow get Christopher'Daggett to
use it on one site? This one seems ideal--it is. small and
manageable, and something we can show to people that we've done
the job. (State Senator 6agliano speaking)
I have a lot of confi denee that Chri s will agree to our
recommendation.
I'm somewhat pleased to hear that we're talking about removing'
the stuff from the site. Quite frankly, I continue to have a
9reat deal of skepticism when it comes to the performance
(implementation) of any plans. Two years ago we talked about the
options that we were goi{'g to implement at one time, and
yesterday, the status is about the same as it was two years ago
as far as onsite work. The only difference is that now that the
fence is gone, you can drive your motorbike right onto the site.
I have a few concerns. .
-------
Issue:
Discussion:
The maximum amount of time shoul d be permi tted for the' oca'
municipality to review the alternatives and allow them to give
maximum input. As I understand, we've only had the report for a
week and now Chris Daggett will be making a decision in a couple
of weeks. I would like, if possible, the opportunity for the
local people to provide input. (Assemblyman John O. Bennett
speaking)
My name is Charles F. Doyle,Jr. [mayor of Howell Township]
many years ago were you here?
How
March 1984.
The reason. I asked that question is because we identified the
problem in 1975 and 10 years later, we're still studying the
problem. What is the cost so far?
Di scuss'i on: About $500,000 so far.
Issue:
Issue:
Discussion:
Issue:
.
You don't have a site at which to dump this stuff once you
excavate it. One of the things Superfund has dragged its feet on
is in locat;ng a place to dump this. "You haven't resolved the
probl em. -
It's not part of Superfund to provide a place to dispose the
material. It is the State's responsibility to find or procure a
secure landfill.
We're happy to see EPA here.
NJDEP. -
We are not satisfied with the
Discussion: There is a representative here, Beth Muhler.
Issue:
Discussion:
I $Sue:
Discussion:
May I ask what part of this sprawling bureaucracy you're from?
I represent the State's 1ead; I am the State's project officer
for this project. I have the State input, and I am responsible
for coordinating the review of all our reports. State input has
been directly given in this project; a meeting was held two weeks
ago going over the different alternatives and we (NJDEP) agreed
to what EPA is recommending. -
Nobody"from the State involved with potable water is here
tonight. This site is close to major drinking water supplies for
the whole county and the NJDEP doesnlt seem to have any concern.
I bring this up because those folks are hellbent on building a
reservoir yet they aren't concerned with any serious
environmental reports.
The Division of Water Resources has reviewed all of these
reports. I can guarantee it, because 11m the one who has relayed
their comments to the EPA.They have thoroughly reviewed a11 of
these reports and they also agree with the recommendation of the
. EPA.
-------
Issue:
Discussion:
Issue:
Discussion:
Issue:
Discussion:
Issue:
Discussion:
A lot of people have spent a great deal of time delivering their
input to you. What 1 want to know is if you are willing to take
citizen input and possibly change your mind because of it. If
you have already decided on the $7 million alternative, say so
now and let's get on with it. Donlt waste the valuable time of
the people. I want to see something accomplished; 1 don1t want
to delay anything.
Welre making a tentative recommendation based on what we know
now; our evaluation is that this $7 mill'ion option here is the
most effective remedy. Weill be glad to sit down with you next
week. and if you can present us with information that would cause
us to change our minds, weill change our minds.
Even if you go with the $7 million option. it would still take
approximately one year to prepare bid documents.
It would be approximately 6, to 8 months.
This is a nice site environmentally. small and contained--yet we
spend half a million dollars to study it and we haven't done
anything with it. When will you start to clean it up?
After 18 months. that's the point we have now reached. When you
go out to these sites. there's no getting around that you walk
onto an empty field. There's no way to stand on top of that
field and know how much is there. where it is. how deep it is.
which way the groundwater moves. whether it goes up. down. north.
east. south or west. toward wells or away from wells. into
streams, and at what rate, and how fast. Before you can start
making a decision on what to do about it. you have to know those
answers. And to get an answer concerning the groundwater, you
have,to install wells. '
It's time consuming. expensive. and a slow process. Sampling
takes time and it is very expensive-eat $1000 a sample. The
sampling and analyt1cs take 60-90 days. There are an enormous
number of samples. We've had some delays in this project which
have frustrated us. but our ~easibil1ty Studies do tend to take
about 18 months to complete. We're not having a lot of success
getting them completed under that time period. It's simply the
nature of the business. We just don't want to go out there and
start digging.
Is criminal prosecution taking place against the owner?
Our priority is to clean up the site and then worry about who is
to blame. ' .
-------
ATTACHMENT 2
-------
.0
'1' tt '\' N SHill tt f
H tt \\' I~ I~ I~
Post OHic. Box 580
Howell, New Jersey 07731
201.938.4500
Sept£mb~ 18, 1985
MayOJl a.nd TowYL6hip CommLUee
T owY'...6hip 06 Howell
VeaIL May".... dnd Tou:r...6h-(.p Co~ee:
Attached ~e cc~e~ ~egat~g Bog C~eek f~
I(!h..{ c.h 1 u1'Imer:te.d on a.t the ~ec.ent mewng on
th.{~ ~ubjcd..
. V e.- 'ty btu4' Y (! UJt.l> ,
, .
t "':' !.
.
/:1 CHAfL FERGUSON
VICE CHAiRMAN
H(it;.:ELL TO;;.'\SHIP fNVIRC,'-:'.~E~'TAL CCMMISS10N
MF,'GC
r..c. :
J(!hr. Czapo~, U.S. EPA
s. T;:o",11.6 Gag.t.ial'l0, S(r'~;:C1J:.
-------
t~LCOME TO BOWELL.
I HAVE SOME QUESTIONS CONCDJlING THE S'l't7DY.
PAGE 1-9. "IT IS EMPHASIZED WITH '!'BE SITE IS A FtJNCTION OF EX-
IST~NG CONDITIONS." "PUBLIC HEALTH RISK COULD INCREASE SIGNIFI-
ICAN'l'ALLY WITH CHANGE IN LiUlD USE. EXAMPLES INCLUDE EXCAVATION
OF CONSTRUCnON ON srn:, RESn>EBTIAL DEVELOPHEN'1' COtn'Icroous WITH
THE SI1'E AND J:NSTALLATION OF NEW GROUND~'1'ER SUPPLY WELLS."
'l'HIS LOW RISK IS A'l'TRIB1J"1'ABLE TO THE FACT '!'BAT '1'BERE IS VERY
LI'l"l'LE JmMAN EXPOSURE TO THE SITE CONTAMIHATION.
WILL '!'HE AGENCY PREVENT OR ASSIST IN PREVENTING DEVELOPMENT AND
'!'BE INCREASED BEAL'l'B RISKS?
THE WILDLIFE SECTION IS VERY MINIMAL CONSIDERING THE FACT THAT
FOeR ENDANGERED OR 'l'BREA'l'ENED SPECIES OCCtlR WITHIN ONE KILE OF
'!'BE SITE .
THEY SHOULD BE CAREFDLLY CONSIDERED
CONSIDERING YOU PROPOSE TO POMP FOR
OF THE. AQUIFER. ALSO 'l'BE EFFECT ON
'!'BE AREA MUST BE ADDRESSED.
IN THE POMPING ALTERNATIVE,
30 YEARS, DROPPING 'l'BE LEVEL
EXISTING SHALLOH WELLS IN
THE DRAFT WARNS THAT 'l'BE STUDY'S CONCLUSION MUST BE VIEWED AS
APPROXIMATE DUE '1'0 FINANCIAL CONSIDERATION.
PAGE 1-11. "ALL ENGINEERING CALCULATIONS, GRAPHICS, COST ESTIMATES,
AND CONCLOSIONS PRESENTED IN FS REPORT ARE ONLY APPROXIMA1'E.. COUPLED
WITH 'l'BE FACT THAT 'l'BERE IS PRESENTLY NO MONEY FOR 'l'BE PROJECT LEAVES
US MORE THAN A LITTLE SKEPTICAL. ARE YOU ABLE TO REASSURE US AT THIS
TIME?
WERE STUDIES CONDOCTED OF THE SOIL BIOTA? IS IT STERILE? HAVE ORGANISMS
MUTATED, ARE 'l'BEY ACCUMULATING CONTAMINANTS? IN PARTICULAR :n. WODLD.
BE FEED UPON BY MIGRATING WOODCOClt wao HAVE LONG USED THIS SITE.
OPENING YET ANOTHER AVENCE OF RECEPTION, AS TllESE BIRDS CODLD EASILY
BE IItJN'1'ED AND C014SOMED IN SOU'l'B CAROLINA OR MASSACBUSET1'S FOR 'l'BAT
MAT'l'ER. IN ADDITION DO ANY PLARTS S'1'ORE 'l'BESE SUBS'1'ANCES OR DO TIlEY
INDUCE ANY CJlEMICAL CBANGES IN '1'BE PLABTS '!"BAT WOULD MAD THEM MORE
AT'l'RAC'l'IVE OR DANGEROtJS TO CONSUMER SPECIES?
'l'HIS. SAME QUESTION WOULD APPLY '1'0. INSECTS.
'l'BE PERTINARCE or 'l'BESE QUESTIONS IS 'l'BE FACT THAT DISPERS~ ROUTES
WERE NOT DISCUSSED ADEQOATELY, INCLUDING 'l'HROOGB AQUATIC ORGANISMS.
HOWEVER THESE AVENtJES SEEM 'l'O HAVE BEEN OVERLOOKED.
-------
IN VIEW OF THE REFRESHINGLY HONEST STATEMENT OF APPROXIMATION,
BOW COME THE RESERVOIR AUTHORITIES CONTI~i!E TO BE ~-RTAIN ~T
THERE WILL BE NO EFFECT: HAVE CONSULTATIONS BEEN HELD WITD
THOSE RESPONSIBLE FOR TEE RESERVOIR?
WILL THE E.P.A. .CONSIDER PURCHASING ADJACENT LANDS?
.
ALTHOUGH YOU STATE FLOW IN TEE UPPER KIRKWOOD IS TO THE NORTHEAST,
YOUR MAPS SHOW SOIL AND ~TER CONTORINATION EXTEND TO THE SOUTH
OF THE PIT. CAN YOU EXPLAIN '.rmS?
DOES THE ENTIRE SURFICIAL AQUIFER EMP'l'Y 'l'O THE W1.TERCOURSES OR
DOES SOME BYPASS THEM? .
TEE STUDY SAYS THE OWNER WAS A MR. FRED BARRY. WILL EITHER CIVIL OR
CRIMINAL PROSECUTION TAItE PLACE AGAINST HIM OR THE COMPANIES OF
ORIGIN?
PLEASE CONSIDER ELIMINATION OF THE NO ACTION, AND ON SITE DISPOSAL
ALTERNATIVES.
PAGE 4-51. STATED THERE WAS NO CONTAMINATION IN THE SHILDNECHT WELL,
BUT THE COUNTY BOARD OF HEALTH TOLD THEM IT WAS CONTAMINAGED.
PAGE 7-15 STATES THERE IS CONTAMINATION. A STUDY OF MINGANABONE
BROOKS FISH POPULATION IS SHOWN AND STATEMENT MADE THAT SQUANltUM
SHOULD BE THE SAME. A STUDY OF SQUANltUH BROOKS' FISH AND ~QUATIC
BIOTA SHOULD BE DONE AND THIS COMPARED TO THE MINGAHAHONE STUDY
TO PROVIDE INFORMATION ON THE EFFECTS ON LIFE IN SQUANltUH. THE
STATEMENT ON 7-33 THAT LEVELS IN THE BROOKS ARE SUITABLE SHOULD
BE SUBSTANTIATED BY AN INVENTORY OF THE AQUATIC BIOTA.
MICHAEL FERGUSON
VICE CHAIRMAN
HOWELL TOWNSHIP ENVIRONMENTAL COMMISSION
-------
TOWNSHIP of HOWELL
Post Office Box 580
Howell, New Jersey 07731.{)580
(201) 938.4500
Septembeit 17, 1985
MIt. John CZapOIL
u.s. EnviJLonmental PILotection Agency
New J eJL6 ey R emecU.a.l Ac.ilon BJuvtc.h
26 FedeJLal Plaza, Room 402
New YOILk, New YOILk 10278
RE: Bog CILeek FdILm (HoweU. Town4Mp) RemecU.a.l Vu.ign
. a.nd RemecU.a.l Action .
VedIL MIt. C Z~OIL:
The enc.tO.6ed .6untmdt.ion dea.L6 wlih the w.u.dU.6e
popula,ti.On4 60u.nd wlih.i.n. the dJLa..i.na.ge 06 the
NolLth and. South BJuvtc.hu 06 SqW11l.kum BlLook dnd.
the PILobable .unpaw that Bog CILeek W had on
them .
Sbtc.eJlel.y YOUJrA,
(/J2W f~
ALFRIJ C. SAUER
Cha.iJLman, Sub-Committee
FdILmland. PILUeJlvdt.ion dnd. lIJ.u.dU.6e Manageme.n;t
H oweU. EnviJLonmental C ornm.i.6.6.ion
ACSIa.c.
c.c.: New JeJL6ey VEP
A.6.6emblyman JohnO. Bennett, 111
SeM.tolL S. Thomd.6 GagLi.o.no
MayolL dnd. TOWn4Mp Committee, wlo ene..
MembeJL6 06 the Cornrra.iA.6.ion, wlo ene..
-------
-
9"5
A SUilUATION Of fIIILf)UfE
fIIITHIN THE
SQJJANKUM BROOK SVSTBI
80TH
p~ ANO PRESENT
BY
AifREf) C. SAUER
-------
A SUiiKATJ:OB OF 1IJ:LDL1:FB WI:TBDl TIlE SQUARJrnM BROOK
SYS'l'EM, . BO"l'H PAST ABD PRESENT
.
BY
ALPJUm C. SADER
BOWELL BllVDtOIDlBlllTAL COIOaSSIOB
The following ~ext should afford the reader a better understanding
of the wildlife that exists within this sub watershed system.
Woodcock (PhU.ohei.o. nW.n.OIl):
A small game bird with a
long bill, principal food is earthworms, migratory with
some nesting range in New Jersey.
Prior to Bog Creek Farm the bog area and the area that lies
inbetween the pon~ and the North Branch of Squankum Brook was a prime
resting and feeding area for woodcock during their fall migration.
However, after 1975 field surveys produced no woodcock in this area.
In addition, traditional nesting areas 3/4'5 of a mile south west of
the site were suddenly devoid of any birds, both resident and migratory.
At this time we felt that the woodcock population might be declining.
However, we were informed via ~orrespondence with the New Jersey
Di~ision of Fish and Game that the state's woodcock population, both
resident and migratory was indeed well and stable.
An area of prime concern is the transfer of lead and/or other
contaminants
to feeding woodcock via the existing earthworm population.
The question still remains, is Bog Creek Farm the cause or a contributing
factor in the decline of woodcock in this area.
Bob-White (CO~ v~g~):
A small game bird, not
migratory, principal foods insecta, seeds, soybeans, and
corn when feeding on cultivated lands.
-------
~hree coveys of Bob-White quail could normally be found in the
&oybean field adjacent to Bog Creek Farm with one covey of about 15
bi~~s utilizing the bog area for cover.
These birds used the higher
ridges north of the North Branch-of Squankum Brook to covey during
i;,~ 11,19ht.
The second covey utilized the area around the old pig tarm
at about the confluence of the North and South Branches, while the
third covey utilized a heavy thicket of briars and pine southwest of
the pig farm.
Our concern here is the transfer of contaminants: via
plants to insects during the summer when these birds feed on insects
and airborne concentrations of contaminantae in field crops during
the fall when the coveys are using standing crops as a food source.
The average number of combined birds in these three coveys
was about SO.
Later field surveys showed a marked decline in all
three coveys.
Although this decline could have been caused by a
number of natural things, such as poor nesting conditions or
extremely severe winter conditions, the possibility still exists of
contamination of the food chain.
Ruffed Grouse (BO~d wmbettu4): A large game bird, found
in heavy woodlands of mixed pine and oak, foods consist of
acorns and berries.
Although these birds are quite numerous in the woodlands to
the east and southeast of the. 80g Creek Farm site, they never seemed
to range onto the site or the woodlands adjacent to the North Branch
of Squankum Brook.
We feel that the. site poses little, if any threat
to this game bird.
Ring-Necked Pheasant (p~~ Cdtchi~ tOAq~):
A large game bird, frequents open fields and woodland
edges.
-------
The iUlIg-i...,,;;..ti!d Pheasant has not reproduced in the Squankum
~~uuk JLdl11~YC b~~ce
i..in;~ .wil1 1950 I s.
This has been due to changes in
land use, and the loss of wild oyergrown meadows on the South Branch
of Squ8nkurn ~r~o~. cast of Route 547.
Although occasional birds are
found, they have normally been released somewhere'else and have traveled
to the site.
A single bird was collected in November of 1971 from the
bog area.
Whitetail Deer:
The North Branch of Squankum Brook from the
bog to its confluance with the South Branch is primarily a
crossing area and is utilized to travel to and from feeding
and bedding areas.
Deer populations are normally high in the
Squankum Brook drainage with the heaviest traveled areas located
on the east side of the South Branch.
Estimated populations
are 20 deer per square mile of undeveloped land.
The South Branch of Squankum Brook supports the following amphibians
and reptiles.
We will list only those species which have been captured
within the drainage.
Salamanders:
Red Backed (P. c.UteILeu.6.) . .'.
Eastern Mud Salamander (P~eudO~O~ monta~ montanu4)
Turtles:
Eastern Box (TeJtIUZPent CJVlO.u.na CJVlo.u.na1
Spotted (Clemmy~ gutt4ta)
B09 turtle (ClennyJ. MuhlWeJlgi)
-. ..Eastern Painted (C. pic.t4 pic.t4)
Red-Bellied (C~~emy~ ~v~)
Snapping turtle (Chety~ J.~tntina)
-------
F1."ogS:
Wood Frog (R. JJyl.va;Uco.)
Pickerel Frog (R. pal.uJJ~)
Southern Leopard Frog (R. ~~)
Green Frog ~R. ~f~~/ta~A mel4nota)
Snakes:
Eastern Milk Snake (Lamp~op~ ~gulum ~gulum)
Northern Water Snake (N~ JJipedon JJipedon)
Red Bellied Snake (Sto~o~ o~cipitOmd~t4)
Northern Brown Snake (StoILeJUa. de.tz.o..yi.. deka.gi..)
Eastern Garter Snake (T. JJ~ JJ~)
Rough Green Snake (Opheo~JJ 4eJJ~)
Northern Black Racer (C. COnJJ~ctolL ~OnJJ~ctolL)
Eastern Kingsnake (L. getuluJJ getuluJJ)
Fish species within the South Branch of Squankum Brook:
Gras s Pic k e re I (Eil 0 x. am CULic..a.nnu.6 veJr.nIi..c.u..l..aA.u..6)
A small member of the Pike family,
length 10 to 11 inches.
American Eel (Anguilla ILOJJ~I
A snake like catadromeus fish.
average
Brown Bullhead (1~ nebuloilUJI)
A medium sized catfish.
Golden Shinner (Notemi..gonUJI ~iloteu~)
A medium sized bait fish.
Bluegill (Lepomiil m4CILO~)
A small panfish.
pumpkinseed (Lepomiil gibboilUJI)
A panfish smaller than the Bluegill,
6 to 7 inches.
Largemouth Bass (MiCILopte1UL6 AaLlnoi..dU)
A large game fish reaching 7 to 8 pounds.
Brook trout (Salv~ 6o~)
Brown trout (Salmo ~)
Rainbow trout (SaLlno gailLdnCULi)
-------
Th~ pr~dominant spc~ies ec~t of Route 547 and prior to the
confJ\1ance of the North Branch are Grass Pickerel, American Eel and
Hrown 'Rn11head.
\
Thp. pT~Ap.n~e o~ Brown Bullhead in comparatively
if; 'Ji. ...,.nbers is
due to +hp. hrp.aching of a dike on an upstream
irrigation system west of Route 547.
Prior to the establishment of the upstream irrigation pond
Brown Bullhead existed within the South Branch of Squankum Brook,
but were extremely rare.
The presence of Golden Shinner and an
occasional Large Mouth Bass and Bluegill are once again due to
the existence o~ the upstream impoundment.
Pumkinseeds have
'always been within the system: but like the Brown bullhead they
were originally quite rare.
We have received reports of trout
captures from within the irrigation pond as recently as two years
ago, although we did not verify these captures.
However, in the
fall of 1963 a trout escaped from our bait sein while we were gathering
Golden Shinners from this pond.
Prior to Bog Creek Parm the South Branch contained all three'
species of trout with the highest populations appearing in late summer.
and early fall.
Although Brook trout was the predominant species,
Brown and Rainbow trout were a180 numerous.
We feel that a great
many of these fish migrated upstream from the Manasquan River.
The 'South Branch of Squankum Brook, not only affords cold water
temperatures, but .lso a compatible pH factor.
It would appear that the discharge from Bog Creek Parm via the
North Branch has severed the link between the upper Teaches of the
South Branch and the Manasquan River.
Although this discharge may
or may not be toxic to trout, we feel that they will avoid entering
-------
it ~imply becuuSe or iLs ch~m;~~l
nC'ture.
.,..,.," .-, ..~ "
"""'\J.~L..",v"ClJ ""1) 1I''1J ':S
: ;JO ~ ;.c:. v~ ut::~l1
sighted within the Squankum
Brook system.
G!'e~' v~~ ~.:easel
:R~d Fox Rabbit
Grey Squirrel Redtail Hawk
Red Squirrel Coopers Hawk
Opossum Sharpshin Hawk
Raccoon Great Horned Owl
There are a qreat many other species of small animals and
birds that could be added to this list.
However we feel that
we have listed the principle animals of the system.
We are sure
that you. will aqree that the Squankum Brook system is rich in wildlife
and that any cleanup plan must qi ve consideration to these existing
populations.
9/85
..
-6-
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
DATE.
SEP 3 0 1985
FROM:
Comment Letter on Bog Creek Farm RI/FS from Michael Ferguson,
::::1:c::::::1:r:::::o:::::: Conuuision - ./ ~ j
Northern New Jersey Remedial Action Sectio':::o"{ . " A~ -' - <-y
File
iUBJECT:
TO.
Mr. Ferguson's letter raises several questions, many of which
were addressed during the public meeting. The responses to
these questions are contained in the Responsiveness Summary
in Attachment 1 to the Summary of Remedial Alternative
Selection for Bog Creek Farm. The questions that were not
raised at the public meeting are addressed below.
The selected alternative will remove the source of contamination
from the site as well as any contaminated material present at
the surface. The recommendation also calls for additional
study to ensure that health risks are adequately addressed.
The purchase of adjacent lands is not required to protect
public health or the environment. Adjacent lands, with the
exception of the bog, which is to be removed, have not been
significantly impacted by the site. The remedial action to
be taken at the site will prevent any future contamination of
adjacent properties.
The Upper Kirkwood Aquifer flows to the north and east at the
site. Measurements of water levels in shallow wells on both
sides of the North Branch of Squarkum Brook indicate that the
brook entirely intercepts the flow of this aquifer. Small
amounts of contaminants have migrated south, against the flow
of the aquifer. This migration is due to diffusion of the
chemicals in the aquifer.
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ATTACHMENT 3
State Intergovernmental Review
..
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STATE OF NEW JERSEY
DEPARTMENT OF COMMUNllY AFFAIRS
DMSION OF LOCAL GOVERNMENT SERVICES
September 23, 1985
363 VVEST STATE STREET
CN 803
TRENTON. N. J. 08625-0803
JOHN P. RENNA'
Mr. John Czapor, Chief.
Northern New Jersey Remedial ~ction Section
u.S. Environmental Protection Agency
26 Federal Plaza, Room 402
New York, N Y 10278
RE: SAI NUMBER:
APPLICANT:
NJ 85-9033
u.s. Environmental Protection ~gency
New Jersey Remedial ~ction Branch
26 Federal Plaza, Room 402
New York, N Y 10278
CONTACT PERSON:
CPDA NUMBER:
PEDERAL PROGRAM:
PROJECT:
John Czapor
66.802
Hazardous Substance Response Trust Fund
Bog Creek Farm (Howell Township)Remedial
Remedial Action
Design &
Pursuant to the system developed in New Jersey for the intergovernmental
review of applications for Federal financial assistance and direct Federal
development activities, the above referenced project has been submitted to the
state Review Process and comments from the Reviewing ~gencies identified on
Page 2 have been received and are transmitted herewith.
Should you have any questions, please do not hesitate to contact us at
(609) 292-9025.
~::~..\~
Nelson S. Silver, PP
Administrator
Intergovernmental Review and
Assistance Unit
for the Single Point of Contact
NEW JERSEY STATE REVIEW PROCESS
cc: Applicant. (without comments)
016S/0547
.
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/
,
( )Atla~tic
( ) Bergen
( )8urlington
( )Camden
-2-
COUNTY REVIEWING AGENCIES:
( ) Cape May
( )Cumberland
( ) Essex
( )Gloucester
( )Hudson
( )Runterdon
( )Mercer
( )Midd1esex
( )ALL 21 COUNTIES
( )Agriculture
( )Commerce
( )Community Affairs
( )Corrections
( )Defense
( ) Education
( ) Energy
STATE REVIEWING AGENCIES:
( )Environmenta1
Protection
( )Governor's Office
(X)Monmouth
( )Morris
( )Ocean
( ) Passaic
( )Sa1em
( ) Somerset
( ) Sussex
( )Union
( )Warren
( ) Law
( )Hackensack Meadowlands
Development Commission
( )Realth
( )Higher Education
( )Human Services
( ) Labor
( )Pinelands
Commission
( )Public
Advocate
( ) SLEPA
( )Transportation
AREAWIDE AGENCY:
OTHER REVIEWING AGENCIES:
( )Air Force
( ) Army
( )Wilmington Metropolitan Area Planning Commission
t..
)
"
NJ 85-9033
\,
( )Navy
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"
REV I ~ WIN ~
II (~ J' ~J I.: Y
. -
(. I) ~ M E .~ ':'
r. E .~ T E H
completion of ~ of th,.. inf"Hflli1~inn rF>r'juirpr! in it~ms 1;-12 is p'!;"enti.ll
hefor~ the Si~qle POint of Cuntact wi 11 forwarrl your commentR to the Fe~eral
funt'ling agency. The informt\tion (or items 1-':1 rp.lating to this particular
application has been compl~te~ hy th~ Statp. Review Process.
RE: (1)
( 2)
(3)
( 4)
State Application Identifier: NJ 85-9033
Name of Applicant: U.S. Environmental Protection Agency
New Jersey Remedial Action Branch
66.802
Hazardous Substance Response Trust Pund
CPDA Number:
Federal Progra,n:
(5)
project Name:
Bog Creek Farm (Howell Township)Remedial Design
, Remedial Action
(6)
The above id~ntifie~ app1ication for Federal financial
assistance or Di~ect Development Activity has been reviewed by this
agency as required by the State Revi~w Process. Our specific
recommen~ation is that the application or activity be:
~ Approveti.
Approved with the connitions set forth below.
::::: Disapproved for the .reasons set forth below.
COMMENTS
u;r-~r.:!tJ~n
5 ~ ~..: Ii..' (..: II ... ii'>A U
SEP :. ~ 1$5
t:RuAN ASSISTA~l::;E UNIT
REV I E WIN G
AGE N C Y
IDE N TIP I CAT ION
Should you have any questions regar"ing these comments, please contact:
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, ':1::;::; ,:- ~ r ~ oe. ~.., l J :/v. J.
(7) Name:
(8) Title:
(9) Agency:
(10) Address:
(11) Telephone Number:
(-~ f) i )
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(12) Signature ~~
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cc: STATE REVIEW PROCESS, Division of Local Government Services, CN 803,
Trenton, NJ 08625-0803
0569/01-85
MONMOUTH COUNTY PLANNING BOAR
HAI.L OF' RECOROR ANNEX
p~ On-ICT. Box 12!,)!)
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